After a de facto prolongation to August 16th, 2018, the deadline for initial registrations with the Beneficial Owner Register Act has expired (see our article of August 6th, 2018). Legal entities that have not fulfilled their legal obligations of identifying their beneficial owners and enlisting them in the register are receiving mail of their competent tax office these days. These letters which are dubbed “Reminders” are not merely well-meant calls for action, but they also contain a threat of enforcement fines.

The letters threatening the assessment of an enforcement fine (e.g. EUR 1,000) contain a period of grace to comply with the obligations of the WiEReG. If the registration is filed within this usually generously set period of grace (approximately 3 months), enforcement fines can still be avoided.

Even though the tax offices’ letters contain a period of grace, outstanding registrations should be completed without further delay. This is due to the fact that a grossly negligently or intentionally wrong registration or non-registration can be fined up to EUR 100,000 respectively EUR 200,000.